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You are here: Area of Law Tax Corporate Tax: Regulation & Guidance IRS Guidance On Loan Origination By Foreign Entities

IRS Guidance On Loan Origination By Foreign Entities

Loans by Offshore Entities to US Borrowers May Constitute Effectively Connected Income

Arnold & Porter
October 6, 2009

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Offshore funds engaged in U.S. trade or business

Freshfields Bruckhaus Deringer
October 2, 2009

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IRS Concludes That Foreign Lender Conducts a U.S Trade or Business

King & Spalding
October 2, 2009

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IRS Ruling Guidance on Lending Activities of Foreign Entities is a “Shot Across the Bow”

Milbank
September 25, 2009

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IRS Scrutinizes Offshore Hedge Fund Lending

Kilpatrick Stockton
September 30, 2009

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IRS Draws Battle Lines in Examinations of Foreign Lenders Using Third-Party Originators 

Patton Boggs
September 29, 2009

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